Business conduct
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As part of Gunvor’s ongoing commitment to responsible conduct, the group’s Governance structures and processes continue to evolve and expand to align with the growing needs of the business and the emerging expectations of our stakeholders. As we look back to 2024, Gunvor has implemented significant improvements in its compliance program, demonstrating a firm commitment to regulatory excellence and ethical conduct. The Compliance Department has now expanded to a team of 36 professionals stationed across key global hubs, including Geneva, London, Singapore, Madrid and Bogotá. This expanded footprint ensures a localized, risk-sensitive approach to compliance management and enables timely intervention across regions. Moreover, the creation of a dedicated remediation team in Madrid and the establishment of a sanctions compliance unit underscore Gunvor’s proactive stance in addressing both legacy issues and evolving regulatory challenges.
Equally notable has been the refinement of compliance controls and internal governance. Gunvor’s policies—such as the Anti-Bribery & Corruption and Anti-Money Laundering frameworks—have been updated and reinforced with stricter enforcement mechanisms. New risk evaluation tools were introduced in early 2025, allowing for enhanced categorization of counterparties, thus streamlining resource allocation for high-risk cases. Additionally, the “Speak Up” whistleblowing platform was overhauled to align with global best practices, encouraging transparent and anonymous reporting. These collective efforts, coupled with regular audits, comprehensive employee training, and enhanced monitoring protocols, reflect Gunvor’s ongoing commitment to compliance maturity and ethical business conduct.
Business conduct policies and corporate culture
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Code of Conduct & Ethics
Gunvor’s Code of Conduct & Ethics is pivotal in guiding the behaviour of employees, contractors, and third-party business partners. Built on a platform of integrity, responsibility, and ethical engagement, the Code articulates the group’s expectations regarding anti-bribery and corruption, human rights, sanctions compliance, health and safety, and environmental considerations. Throughout 2024, Gunvor regularly updated and redistributed the Code to ensure employees are thoroughly familiar with its latest provisions and remain aligned with evolving international and local regulations.
Whistleblower Protection
A core mechanism supporting Gunvor’s ethical culture is the whistleblowing process. The “Speak Up” Whistleblowing system was upgraded in 2023 and 2024, aligning with recognized global best practices.
“Speak Up” empowers individuals to raise concerns anonymously and free from retaliation. Reports received via our secure online or telephone-based channels are independently investigated. Once resolved, the findings are presented to the Group Compliance Committee (GCC), which evaluates whether systemic improvements are needed.
Continued Ceased Use of External Agents for Origination Policy
Since 2021, Gunvor has phased out third-party agents used for business origination. This policy has persisted into 2024, and Gunvor now relies on only a small number of third-party consultants, strictly limited to specialized technical or operational services. This measure lowers bribery and corruption risks and bolsters transparency in the origination of new business ventures.
Animal Welfare
Given our core activities in commodity trading, refining, shipping, and logistics, Gunvor does not engage in operations that involve direct or indirect handling of animals. We therefore do not have an animal welfare policy, as it is not applicable to our business activities.
Public Commitments and Reporting
Gunvor strives to consistently enhance its transparency, supported by both internal governance processes and recognized frameworks. As part of these efforts, Gunvor continues to align its sustainability disclosures with the emerging standards of the ESRS as part of CSRD. This approach ensures our non-financial data—covering environmental, social, and governance (ESG) topics—remains comprehensive, credible, and comparable.
Gunvor publishes key documentation and guidelines on its website, detailing our Compliance governance, Code of Conduct & Ethics, Human Rights Policy, and Modern Slavery Statement. We maintain an open dialogue with industry bodies and regulators, contributing to collective efforts to strengthen governance standards across the commodities sector.
Management of relationships with suppliers
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Know Your Customer (KYC) and Supplier Due Diligence
Gunvor employs a single centralized system for all counterparty due diligence, the Counterparty Management System (CMS). This system enforces thorough data collection, adverse media screening, risk categorization, and mandatory approvals.
Compliance KYC analysts are split between staff in charge of onboardings, and those responsible for periodic reviews. A new remediation team in Madrid focuses on addressing any backlog of due diligence reviews.
Gunvor has refined its risk-based approach, allowing for even more targeted enhanced due diligence on high-risk counterparties, by redesigning the risk formula from ground-up, and by enhancing its risk categorization, better sorting counterparties into four levels (e.g., low, medium, high, and very high risk), with clear rules regarding corresponding reviews periods.
This system better prioritizes resources for mitigating the highest risk activities and counterparties. Senior compliance personnel conduct regular quality checks on new KYC files, ensuring consistent application of policies and rigorous detection of red flags.
Prevention and detection of corruption and bribery
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Embedding Compliance: Training and Culture
Gunvor invests significant resources into training and professional development to foster a culture of compliance across the organization. Annual mandatory training in anti-corruption, AML, sanctions, market abuses, and know-your-customer (KYC) processes is provided to every white-collar employee. New hires receive specialized onboarding, including the fundamentals of Gunvor’s Code of Conduct & Ethics. Specific high-risk functions such as Business Development Origination, Front Office Business teams, Portfolio Management team – M&A, Structured trade finance teams are subject to enhanced oversight, including:
Trading & Advisory Compliance
Zero Tolerance Policy
Gunvor’s stance on corruption and bribery remains unequivocal: zero tolerance. This guiding principle is reaffirmed each year through targeted anti-bribery training, management briefings, and official communications from senior leadership.
Monitoring and Reporting
Gunvor continues to apply specialized communication monitoring and transaction-testing to detect irregularities or breaches of compliance rules. Where potential issues arise, the GCC is notified immediately, enabling timely remediation. Gunvor also remains subject to periodic reporting related to legacy matters, demonstrating ongoing improvements in its anti-bribery and compliance controls.
Incidents of corruption or bribery
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We also endorse the Extractive Industries Transparency Initiative (EITI), the globally recognized framework for ensuring that revenues from oil, gas and mineral extraction are managed openly and accountably. Under the EITI Standard—which applies to companies across the extractive sector—participants must disclose information at every stage of the value chain: from the moment resources are extracted, through the flow of payments to governments, to the ultimate benefit of the public.
As part of EITI, Gunvor reports all payments and volumes (where available) aggregated at the parent-company level, including those made to state-owned enterprises in EITI-implementing countries where governments hold a majority stake. Across the 55 countries that have adopted EITI, a coalition of governments, companies and civil-society groups supports this work.
Gunvor regards EITI participation as a consistent, reliable way to disclose our government payments, help combat corruption and bolster transparency in natural-resource management. Given the complexity and variety of our transactions, we continue to collaborate with EITI, industry peers and other transparency advocates to enhance our disclosures.
Payment practices
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Gunvor conducts its commercial transactions on an arms-length basis, paying its suppliers and service providers in accordance with contractually agreed timelines. There have been no reported disputes regarding late payments, and no material legal proceedings related to breach of payment terms.
| Related DR | Name | Group |
|---|---|---|
| G1-6 | Average number of days to pay invoice from date when contractual or statutory term of payment starts to be calculated | 5 |
| G1-6 | Percentage of payments aligned with standard payment terms | 100% |
| G1-6 | Number of outstanding legal proceedings for late payments | 0 |
Future Looking statement:
Gunvor recognizes the dynamic nature of governance. Driven by our core values and informed by the evolving standards, we are committed to:
In so doing, Gunvor strives to maintain robust governance arrangements that reflect international best practices. Our approach is built upon a cornerstone of ethical business conduct, ensuring the long-term interests of our employees, investors, and other stakeholders are preserved. Through continued vigilance, transparency, and improvement, we believe Gunvor will remain well positioned to meet the challenges and opportunities of 2025 and beyond.